As a gathering place for innovative and growing enterprises, the ChiNext market is distinctly characterized by its emphasis on 'innovation' and 'growth'. By the end of October 2024, there were over 1,350 ChiNext-listed companies with a total market value exceeding RMB 12 trillion. As one of the companies aiming to list on ChiNext, Guangdong Hongjing Optoelectronics Technology Co., Ltd. (hereinafter referred to as 'Hongjing Optoelectronics') has faced two rounds of inquiries regarding its gross profit margin and period expenses during its listing process.

Furthermore, the commencement date of Hongjing Optoelectronics' subsidiary's construction project may precede the issuance date of the construction planning permit, as well as the corresponding environmental impact assessment (EIA) approval date, presenting an anomaly of 'starting before obtaining the necessary permits'. On the other hand, Hongjing Optoelectronics claims that during the reporting period, it was unable to accurately allocate salaries for some personnel, including Zeng Wei, the head of the Development and Procurement Department. However, in addition to the personnel disclosed by Hongjing Optoelectronics, several non-R&D employees of Hongjing Optoelectronics have also appeared on its list of patent inventors, including Zeng Rong, who serves as the canteen director and is Zeng Wei's sister.

I. The commencement date of the subsidiary's project's main construction may precede the official approval date, presenting an anomaly of 'starting before obtaining the necessary permits'

On September 20, 2023, the Ministry of Ecology and Environment issued the 'Opinions on Further Optimizing Environmental Impact Assessment Work', which emphasized strengthening the investigation and handling of illegal activities such as 'commencing construction without approval' and 'commencing operation without inspection'.

In contrast, in 2022, a construction project of Hongjing Optoelectronics' subsidiary, Hongjing Xiantao, may have commenced construction of its main building before obtaining the construction planning permit. Moreover, doubts also surround the commencement date of the project's solid waste storage area.

1.1 The first round of inquiry responses revealed that the main construction of the subsidiary's smart manufacturing project had commenced in February 2022

According to the 'Response to the Examination and Inquiry Letter Regarding the Application Documents for the Initial Public Offering and ChiNext Listing of Guangdong Hongjing Optoelectronics Technology Co., Ltd.' (hereinafter referred to as the 'First Round of Inquiry Responses'), dated December 18, 2023, the smart manufacturing project of Hongjing Optoelectronics' subsidiary, Hongjing Optoelectronics (Xiantao) Technology Co., Ltd. (hereinafter referred to as 'Hongjing Xiantao'), includes the purchase of land, construction of new factories, dormitories, canteens, inspection workshops, fire pools and pump rooms, solid waste storage areas, guard rooms, power distribution rooms, decoration of new factories, and procurement of machinery and equipment.

Among these, the main construction includes factories, dormitories, canteens, inspection workshops, fire pools, and pump rooms. On February 11, 2022, construction of the project's factories, dormitories, canteens, inspection workshops, fire pools, and pump rooms began; on August 1, 2022, construction of the solid waste storage area, guard room, and power distribution room commenced.

In other words, the main construction of the project had already begun on February 11, 2022.

However, the issuance date of the construction permit for this project may be later than the commencement date disclosed in Hongjing Optoelectronics' first round of inquiry responses.

1.2 Official information shows that the smart manufacturing project obtained land use and engineering planning permits in March 2022

According to the first round of inquiry responses, the land use right for the smart manufacturing project was obtained on March 10, 2022, when Hongjing Xiantao signed the 'State-owned Construction Land Use Right Transfer Contract' with the Xiantao Municipal Natural Resources Bureau, acquiring land parcel number 'XTD [2022] No. 51'.

According to the land transfer results announced by the Xiantao Municipal Natural Resources Bureau on March 5, 2022, the land parcel 'XTD [2022] No. 51' is located in Chuanwan Village, Xiantao Industrial Park, with Hongjing Xiantao as the transferee.

In other words, the smart manufacturing project mentioned in the inquiry responses is located in Chuanwan Village, Xiantao Industrial Park.

According to publicly available information from the Xiantao Municipal Natural Resources and Planning Bureau, the decision date for the 'Construction Land Use Permit' for Hongjing Xiantao's 'Annual Production of 100 Million Optical Glass Lenses and Lens Digital Production Smart Manufacturing Project' is March 17, 2022, and the issuance date of the 'Construction Engineering Planning Permit' is also March 17, 2022.

The 'Construction Engineering Planning Permit' indicates that the project's construction location is in Chuanwan Village, Xiantao Industrial Park, west of Xianhong Road.

By comparing project names, construction locations, and construction unit information, it can be inferred that the above two permits are likely related to the smart manufacturing project.

Comparing the project commencement date with the permit issuance date, it is evident that the main construction of Hongjing Xiantao's smart manufacturing project may have commenced one month before obtaining the construction planning permit.

The 'issues' do not end here. A similar situation may also exist for the project's solid waste storage area.

1.3 The project's solid waste storage area was said to have commenced construction in August 2022, but official announcements indicate that the corresponding construction permit was obtained the following year

As mentioned above, on August 1, 2022, construction of the smart manufacturing project's solid waste storage area, guard room, and power distribution room began.

However, according to publicly available information from the Xiantao Municipal Natural Resources and Planning Bureau, the issuance date of the 'Construction Engineering Planning Permit' for Hongjing Xiantao's smart manufacturing project's 'solid waste storage area' is February 22, 2023.

It is not difficult to observe that the commencement date of the smart manufacturing project's 'solid waste storage area' may precede the permit issuance date.

Moreover, the project's EIA document may not have been approved until two months after construction began.

1.4 The EIA report for the smart manufacturing project was approved in April 2022, potentially later than the commencement date of the project's main construction

According to the 'Environmental Impact Assessment Report for the Annual Production of 100 Million Optical Glass Lenses and Lens Digital Production Smart Manufacturing Project' (hereinafter referred to as the 'Smart Manufacturing Project EIA Report') compiled in March 2022, the project's construction site is located in Chuanwan Village, Xiantao Industrial Park.

By comparing the project name, location, and construction unit information, it can be inferred that the 'Environmental Impact Assessment Report for the Annual Production of 100 Million Optical Glass Lenses and Lens Digital Production Smart Manufacturing Project' is related to the smart manufacturing project and will be referred to collectively as the 'Smart Manufacturing Project EIA Report' below.

According to publicly available information from the Hubei Provincial Investment Project Online Examination and Approval Supervision Platform, on April 8, 2022, the Xiantao Municipal Ecological Environment Bureau accepted the EIA report for Hongjing Xiantao's smart manufacturing project. On April 29, 2022, the Xiantao Municipal Ecological Environment Bureau approved the project's EIA application.

In other words, the commencement date of the smart manufacturing project may be two months earlier than the corresponding EIA approval date.

According to the 'Urban and Rural Planning Law' revised, promulgated, and currently in effect on April 23, 2019, if a construction project is commenced without obtaining a construction engineering planning permit or is constructed in violation of the provisions of the construction engineering planning permit, the competent department of urban and rural planning of the local people's government at or above the county level shall order the cessation of construction.

From this perspective, the first round of inquiry responses stated that the main construction of Hongjing Optoelectronics' subsidiary's smart manufacturing project commenced in February 2022, with the solid waste storage area commencing in August 2022. However, official announcements indicate that the project obtained land use and engineering planning permits in March 2022 and obtained the corresponding permit for the solid waste storage area in 2023. Furthermore, the project's commencement date may precede the EIA approval date. These anomalies suggest that Hongjing Optoelectronics' smart manufacturing project may have 'started before obtaining the necessary permits'.

II. Behind the claim that all R&D personnel are full-time, the canteen director 'contributed' to dozens of patents, raising doubts

On March 16, 2024, the China Securities Regulatory Commission issued the 'Opinions on Strictly Controlling the Access to IPO and Improving the Quality of Listed Companies from the Source (Trial Implementation)'. Among them, it was proposed to strictly control the application quality of companies intending to list.

It is noteworthy that Hongjing Optoelectronics stated that it was unable to accurately allocate the salaries of some personnel, including Zeng Wei, the head of the Development and Procurement Department. However, in addition to the personnel disclosed by Hongjing Optoelectronics, there may also be other administrative and financial personnel appearing on the list of patent inventors.

2.1 Inquiry into the classification criteria for R&D personnel and whether they are full-time, with a claim that all R&D personnel are full-time

According to the first round of inquiry responses, the Shenzhen Stock Exchange noted that from 2020 to 2022, Hongjing Optoelectronics' R&D expenses amounted to RMB 14.7556 million, RMB 20.7554 million, and RMB 28.0668 million, respectively. In 2022, the compensation for Hongjing Optoelectronics' R&D personnel was RMB 18.5596 million, a significant increase from previous years. Hongjing Optoelectronics was required to explain the classification criteria for R&D personnel and whether they are full-time.

In response, Hongjing Optoelectronics stated that its R&D work can be divided into the laboratory development stage and the small-batch trial production stage. The small-batch trial production stage is primarily handled by the technical department and the quality control department, with some personnel in these departments dedicated to R&D and trial production work.

Simultaneously, Hongjing Optoelectronics identified technical personnel engaged in the laboratory development stage and trial production in the small-batch trial production stage, as well as quality control personnel involved in new product inspection, as R&D personnel, all of whom are full-time.

In other words, Hongjing Optoelectronics stated that its R&D work is primarily conducted within the laboratory, technical department, and quality control department. R&D personnel can be clearly classified, and all are full-time.

Curiously, among the patent inventors of Hongjing Optoelectronics, there may be employees from the administrative department.

2.2 Stated inability to accurately allocate the salaries of some personnel, including Zeng Wei, the head of the Development and Procurement Department

According to the first round of inquiry responses, Hongjing Optoelectronics stated that it was unable to accurately allocate the salaries of some personnel, including Zeng Wei, the head of the Development and Procurement Department; Li Feiwu, Zhong Xiaomin, Xian Guicai, and others from the Quality Control Department.

In this regard, Hongjing Optoelectronics stated that the salaries of the aforementioned personnel could not be distinguished between R&D activities and other business activities, so they were all included in other expenses and not counted as R&D expenses.

It can be seen that from 2020 to 2022, Hongjing Optoelectronics stated that the expenses that could not be accurately allocated may only involve some employees of the Development and Procurement Department and the Quality Control Department.

However, doubts surrounding the personnel whose salaries could not be accurately allocated have not yet dissipated.

Let's first focus on the activity distinction of Zeng Wei, the head of the Development and Procurement Department. According to publicly available information from the National Intellectual Property Administration, as of the inquiry date of November 27, 2024, from 2014 to 2017, Zeng Wei, as an inventor, contributed to over 30 patents for Hongjing Optoelectronics.

According to Hongjing Optoelectronics' prospectus dated November 11, 2024 (hereinafter referred to as the 'Prospectus Dated November 11, 2024'), from July 2014 to May 2016, Zeng Wei served as the Deputy Manager of the Supply Chain Management Department of Zhongshan Hongjing Optoelectronics Technology Co., Ltd. (the predecessor of Hongjing Optoelectronics); from May 2016 to September 28, 2024, he served as the Employee Representative Supervisor and Manager of the Development and Procurement Department of Hongjing Optoelectronics.

Judging from the overlap between the time Zeng Wei held relevant positions in the Procurement Department and the patent application period, it is likely that the aforementioned Zeng Wei is the same person.

In this context, Zeng Rong, a related party of Zeng Wei, also appears on the list of Hongjing Optoelectronics' patent inventors.

2.3 Zeng Rong, Zeng Wei's sister and the director of the canteen in the Human Resources Department, may have contributed to 30 patents from 2016 to 2017

According to publicly available information from the National Intellectual Property Administration, as of the inquiry date of November 27, 2024, from 2016 to 2017, Zeng Rong, as an inventor, contributed to 30 patents for Hongjing Optoelectronics. Among them, 25 patents have Zeng Wei and Zeng Rong listed as inventors simultaneously.

According to the Prospectus Dated November 11, 2024, as of September 28, 2024, Zeng Rong served as the Director of the Canteen in the Human Resources Department. Meanwhile, Zeng Rong is Zeng Wei's sister.

It is worth mentioning that Zeng Rong's tenure as the Canteen Director at Hongjing Optoelectronics may date back to 2017.

According to Hongjing Optoelectronics' 'Public Transfer Prospectus' dated January 16, 2017, as of January 16, 2017, Zeng Rong, who is Zeng Wei's sister, served as the Director of the Canteen in the Administrative Department of Hongjing Optoelectronics.

Judging from Zeng Rong's employment history, her familial relationship with Zeng Wei, and their joint participation in patent inventions, it is likely that Zeng Rong, the patent inventor of Hongjing Optoelectronics, and Zeng Rong, the Canteen Director in the Human Resources Department, are the same person. In this case, from 2016 to 2017, Zeng Rong was the inventor of 30 patents for Hongjing Optoelectronics.

The issues continue. After 2020, there may also have been administrative personnel serving as patent inventors at Hongjing Optoelectronics.

2.4 From 2020 to 2024, the financial manager and administrative manager of the subsidiary may have appeared on multiple patent inventor lists

According to publicly available information from the National Intellectual Property Administration, as of the inquiry date of November 27, 2024, from 2020 to the present, Rong Yanhong and Guo Liang, as patent inventors, have contributed to multiple patents for Hongjing Optoelectronics.

However, these two inventors also share the same names with two non-R&D personnel at Hongjing Optoelectronics.

According to the Prospectus Dated November 11, 2024, as of September 28, 2024, Guo Liang served as the Financial Manager of Hongjing Optoelectronics' subsidiary, Hongjing Xiantao.

According to publicly available information dated January 21, 2024, Rong Yanhong is the Administrative Manager of Hongjing Xiantao.

According to information cited by the Xiantao Municipal Government on July 11, 2024, Rong Yanhong is the head of the Human Resources Department of Hongjing Xiantao.

It can be seen that Rong Yanhong and Guo Liang, who are patent inventors for Hongjing Optoelectronics, share the same names as Rong Yanhong, the Administrative Manager, and Guo Liang, the Financial Manager, of Hongjing Xiantao. Considering the uniqueness of their names, it is plausible that the patent inventor Rong Yanhong is the same person as the one from Hongjing Xiantao.

In summary, Hongjing Optoelectronics stated that it was unable to accurately allocate the salaries of some personnel, including Zeng Wei, the head of the Development and Procurement Department, and Li Feiwu, Zhong Xiaomin, Xian Guicai, and others from the Quality Control Department. However, in addition to the aforementioned personnel, Zeng Rong, Zeng Wei's sister who serves as the Canteen Director in the Human Resources Department, is also an inventor on multiple authorized patents of Hongjing Optoelectronics. Furthermore, from 2020 to 2024, the Financial Manager and Administrative Manager of Hongjing Xiantao, the subsidiary, have appeared on multiple patent inventor lists. Furthermore, does this situation indicate that non-R&D personnel may have been involved in patent invention work at Hongjing Optoelectronics? This warrants further attention.